View Rule

Abstract: Update rules for the application of section 267 to partnership transactions. Specifically, questions exist as to the continued applicability of the current regulations under section 1.267(b)-1(b) and and Question 2 and 3 of section 1.267(a)-2T(c) due to statutory changes to sections 267 and 707(b). The regulations will address whether the rules in the aforementioned section 267 regulations relating to partnerships have been superseded by statute.